Williams v. Moberly Correctional Center

Calvin Williams, a person incarcerated in Missouri, tried to file a lawsuit to vindicate his rights—but a court wrongly dismissed his civil rights case under a misapplication of the Prison Litigation Reform Act’s “three-strikes” rule. The MacArthur Justice Center is fighting to ensure that courts don’t erroneously deny people in prison access to the courts. 

The Prison Litigation Reform Act of 1996 (PLRA) governs how people in prison can sue in court for claims of federal constitutional violations. The PLRA creates several prisoner-specific obstacles to federal litigation. 

In particular, any party who brings a federal civil action, but is unable to pay the applicable filing fee, can request permission to sue “in forma pauperis” (IFP). Ordinarily, if a federal court grants a plaintiff IFP status, the filing fee is waived. But the PLRA imposes a different rule for incarcerated plaintiffs. Prisoners who are granted IFP status must pay the full filing fee; IFP status merely authorizes them to pay the fee in installments over time, rather than in a lump sum upfront. And a prisoner who has had three prior federal cases dismissed for certain reasons—what courts call three “strikes”—usually cannot proceed IFP. 

An incarcerated litigant who has accumulated three strikes, and is therefore barred from proceeding IFP, must pay the entire civil filing fee at the outset of their case. For many incarcerated people, it is impossible to pay the full fee upfront—so if they are denied IFP status, they can’t sue at all. 

That is what happened to Mr. Williams. When he sued to vindicate his rights, the district court didn’t consider the substance of his case. Instead, it deemed him a three-striker and ordered him to pay a $405 filing fee, which he could not do. As a result, the court dismissed his case. However, one of the prior dismissals the court deemed a strike was not a strike at all.  

Specifically, one of Mr. Williams’s prior lawsuits was dismissed under a Supreme Court decision called Heck v. Humphrey, 512 U.S. 477 (1994). That’s not a kind of dismissal listed as a “strike” under the PLRA. Although a dismissal for “fail[ure] to state a claim upon which relief may be granted” counts as a strike under the PLRA, a dismissal under Heck has nothing to do with the elements of a prisoner’s claim—it just means the civil rights suit is mistimed, or that it was filed in the wrong form. The MacArthur Justice Center represents Mr. Williams on appeal to the U.S. Court of Appeals for the Eighth Circuit to ensure that incarcerated people aren’t wrongfully denied their day in court based on misapplications of the PLRA’s three-strike rule.